Legal
Privacy Policy
EnVergal is a private home for your family. This notice explains what personal data we collect, why, the lawful basis on which we process it, and the rights you have — including under India’s Digital Personal Data Protection Act, 2023 (“DPDP Act”). In short: your family’s information is never sold, never used to train AI, and always yours to access, export or delete.
1. Who we are (the Data Fiduciary)
EnVergal is a private family-network service at envergal.com, operated by 91 AT WORK LLP(“91 AT WORK”, “we”, “us”). For the purposes of the DPDP Act, 91 AT WORK is the Data Fiduciary that determines how and why your personal data is processed.
Grievance Officer: you can reach the person responsible for your privacy questions and requests at clients@91atwork.com. We aim to acknowledge requests promptly and respond within the timelines required by law.
2. The personal data we collect
- Account details — your mobile number (or email) and a password you choose, so you can sign in securely.
- Family information you add — the people in your family and how they’re related, plus any details you choose to record: names, dates, places, photos, stories, events and notes.
- Content you create — memories, posts, comments, messages and events you share within your family circle.
- Technical data — limited information needed to run the service securely and reliably (for example, to prevent fake sign-ups and abuse).
3. Why we process it, and our lawful basis
We process your personal data only to provide and secure EnVergal — to build your family tree, work out relationships and show them in your language, connect relatives you invite, and keep your account safe. Our lawful basis is your consent (given when you create your account and when you choose to add information), together with what is necessary to provide the service you have asked for. We follow the principles of purpose limitation and data minimisation — we do not use your data for unrelated purposes.
4. Consent, and how to withdraw it
You provide consent by an affirmative action when you create your account. You may withdraw your consentat any time — as easily as you gave it — by deleting your content or account in the app, or by contacting our Grievance Officer. Withdrawing consent will not affect processing already carried out, and may mean parts of the service can no longer be provided.
5. What we never do
- We never sell your family’s data, and we never share it with advertisers.
- We never use your memories, relationships or content to train AI models.
- We do not run third-party advertising, and we do not profile or track you across other websites.
6. Who can see your information
EnVergal is invite-only and private by default. Your family space is visible only to the people you invite, and you control what each person can see (including keeping a profile or a mobile number private). Relatives cannot add themselves, and no one outside your circle can see your family.
7. Sharing, service providers and data location
We share your information only: (a) with the people you invite into your family; (b) with a small number of trusted service providers (Data Processors) who help us run the service under contract and strict confidentiality — currently Cloudflare (secure photo storage and bot-protection) and Google(optional “Sign in with Google”); and (c) where required by law. These providers act only on our instructions. Some of them may store or process data outside India; we take steps so your data stays protected wherever it is handled, consistent with the DPDP Act. We do not sell or rent personal data to anyone.
8. Your rights as a Data Principal
Under the DPDP Act you have the right to:
- Access — get a summary of the personal data we process about you. You can download all of your data from Your profile → Your data & privacy.
- Correction & updating — correct or complete your information (edit your profile in the app).
- Erasure — ask us to delete your personal data and account.
- Nominate — nominate another person to exercise your rights in the event of death or incapacity.
- Grievance redressal — raise a concern about how your data is handled.
You can exercise these rights inside the app (Your profile → Your data & privacy) or by writing to our Grievance Officer at clients@91atwork.com. If information about you was added by a relative, you can claim your profile to control it, or contact us to access, correct or erase it.
9. Grievances and the Data Protection Board
Please contact our Grievance Officer first — we want to put things right. If you are not satisfied with our response, you may lodge a complaint with the Data Protection Board of India established under the DPDP Act.
10. How long we keep your information (retention)
We keep your information for as long as your account is active, and only as long as needed for the purposes above. When you delete content or your account, we remove it from the live service; residual copies in secure backups are overwritten in the ordinary course. We do not keep personal data once it is no longer needed.
11. Security
We protect your information with reasonable technical and organisational safeguards — including encryption in transit, hashed passwords, access controls, private-by-default sharing, and abuse protection. No service can promise perfect security, but keeping your family’s data safe is central to how EnVergal is built.
12. Personal data breaches
In the unlikely event of a personal data breach that affects you, we will act promptly to contain it and will notify the Data Protection Board and affected individuals as required by the DPDP Act.
13. Children and family members who haven’t joined
EnVergal is intended for adults (18+). A member may record family members of any age as part of the family record. Where we process the personal data of a child (a person under 18) or a person with a guardian, we require the verifiable consent of a parent or lawful guardian, and we do not track, profile, or serve targeted content to children. If you are a parent, guardian, or a family member whose information has been added and you wish to review, correct or remove it, please contact our Grievance Officer and we will act on your request.
14. Cookies
We use a single essential cookie to keep you signed in. We do not use advertising or third-party tracking cookies.
15. Changes to this policy
We may update this policy from time to time. We will post the new version here with an updated effective date and version.
16. Contact
Questions or requests about privacy? Email our Grievance Officer at clients@91atwork.com.